Cw Securities, LLC

DISCLOSURE BROCHURE CW SECURITIES, LLC 8870 Cedar Springs Lane Suite 208 Knoxville, TN 37923 This Disclosure Brochure provides clients with information about the qualifications and business practices of CW Securities, LLC Please contact Michael E. Cox, President & Chief Compliance Officer of CW Securities, LLC 865-690-9886 or email mcox@cwmanagement.com, if you have questions about the content of this brochure. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Additional information on the disciplinary history of CW Securities, LLC is available on the Internet at www.adviserinfo.sec.gov/IAPD/. You can search this site by a unique identifying number known as an IARD number. The IARD number for CW Securities, LLC is 124496. Registration does not imply a certain level of skill or training. March 10, 2026 1  1. ABOUT CW SECURITIES, LLC CW Securities, LLC (CWS) is a fee-only, independent investment advisory firm registered with the Securities and Exchange Commissions. Registration does not imply a certain level of skill or training. The expertise and training requirements for all CWS associates are detailed in ADV Part 2B filings. 2. MATERIAL CHANGES As of March 2026 CWS transitioned registration from State of Tennessee to the Securities and Exchange Commission . 3. TABLE OF CONTENTS 1. ABOUT CW SECURITIES, LLC ...................................................................................................... 2 2. MATERIAL CHANGES ...................................................................................................................... 2 3. TABLE OF CONTENTS .................................................................................................................... 2 4. ADVISORY BUSINESS .................................................................................................................... 3 5. FEES AND COMPENSATION ......................................................................................................... 4 6. PERFORMANCE BASED-FEES and SIDE-BY-SIDE MANAGEMENT .................................... 7 7. TYPES OF CLIENTS ......................................................................................................................... 7 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES and RISK of Loss ......................... 7 9. DISCIPLINARY INFORMATION ...................................................................................................... 7 10. OTHER FINANCIAL INDUSTRY ACTIVITIES and AFFILIATIONS .......................................... 7 11. CODE OF ETHICS, PATICIPATION or INTEREST in CLIENT TRANSACTIONS and PERSONAL TRADING...................................................................................................................... 8 12. BROKERAGE PRACTICES ............................................................................................................. 8 12.A.2. Brokerage for Client Referrals ................................................................................................ 9 12.A.3. Directed Brokerage .................................................................................................................. 9 12.A.4. Aggregation and Allocation of Trades ................................................................................... 9 13. REVIEW OF ACCOUNTS .............................................................................................................. 10 14. CLIENT REFERRALS AND OTHER COMPENSATION ........................................................... 10 15. CUSTODY ......................................................................................................................................... 11 16. INVESTMENT DISCRETION ......................................................................................................... 11 17.A. VOTING CLIENT SECURITIES .................................................................................................. 11 18. FINANCIAL INFORMATION ............................................................................................................ 11 CLIENT COMPLAINTS ........................................................................................................................... 11 CLIENT ACKNOWLEDGEMENT .......................................................................................................... 11 2  4. ADVISORY BUSINESS Mr. Cox founded CW Securities, LLC (CWS) in 2000. CWS provides investment supervisory services, defined as giving continuous advice to, or making investments for, clients based on their individual needs. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, CWS develops a client's personal investment policy and creates and manages a portfolio based on that policy. CWS provides this service to individuals, pension and profit- sharing plans, trusts, estates, charitable organizations, and corporations. CWS will manage advisory accounts on a discretionary basis. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income or growth and income). The Asset Management Program offers clients a brokerage account in which CWS’s investment adviser, representatives or other registered investment advisers, collectively referred to as the “Advisers”, direct and manage specified client assets, upon authorization by client. Through the Asset Management Program account, clients authorize their selected Adviser to purchase and/or sell, among other investments, equities, fixed income products, no-load and load waived mutual funds. This is done on a discretionary basis. The Adviser will assist the client in determining, among other things, the client’s suitability for the Asset Management Program by identifying the client’s investment objectives, investment time horizon and investment risk tolerance. Each Adviser selects their own analysis and research methods, investment style and strategies, as well as ongoing management philosophy. The Adviser, through various research reports and model portfolios, advises the client as to which securities to purchase and/or sell. When CWS creates a portfolio consisting of no-load and load-waived mutual funds, CWS will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. The mutual funds will be selected on the basis of any or all the following criteria; 1) performance history, 2) industry sector, 3) track record of fund manager, 4) fund investment objectives, 5) fund management style and philosophy, and 6) fund management fee structure. Portfolio weighing between funds and market sectors will be determined by each client's individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on their behalf. Clients will retain individual ownership of all securities. Other securities that may be offered by CWS for investment in the Asset Management Program include equities and fixed income products. For illustration purposes, the following management styles or any combination thereof may be utilized by Advisers and should not be considered an all-inclusive list. Clients should discuss with their Adviser the specific approach they use when managing Asset Management Program accounts. Fixed Income This management style focuses on purchasing different types of fixed income securities. If utilizing this approach, an Adviser may suggest that the client invest in high quality bonds, lower quality high yielding bonds, or international bonds, depending on the specific objectives of the client. The typical time horizon is 2-5 years. 3  Growth and Income This management style focuses on purchasing a generous allocation of fixed income securities which may include domestic, international and high yield bonds. This style would also include a generous equity component, in hopes of providing inflationary protection for the client’s assets. These securities would include domestic, international and emerging markets securities. The typical time horizon is 4- 10 years. Growth For clients seeking growth, this management style might be utilized. It seeks growth potential from domestic, international and emerging market securities with a minor allocation of long-term bonds and money market instruments. The typical time horizon is 10-20 years. Aggressive Growth This management style seeks above average growth by seeking capital appreciation from an aggressive mix of equity securities, including domestic, international and emerging markets securities. Depending upon the Adviser, the portfolio could be further diversified between different types of fund managers, including those who focus on small and large sized companies and who may utilize unique styles of equity management including value and growth. The typical time horizon is 15+ years. All recommendations are based on the individual client’s financial status (net worth excluding residence, annual income, employment history and tax bracket), investment objectives, age, and investment experience. Clients have the opportunity to place reasonable restrictions on the types of investments that will be made on their behalf and will retain individual ownership of all securities. As of December 31, 2025, CWS managed 229 accounts with $113,478,500 assets under management on a discretionary basis. 5. FEES AND COMPENSATION Asset Management Program All Asset Management Program transactions will primarily be executed through the utilization of Charles Schwab & Company, Inc. (Schwab) or American Funds. CWS utilizes the clearing and custodial services of Schwab and their affiliates or other companies, as applicable. All transactions with American Funds are executed via application and reinvestment. Under the Schwab program as a participant in the Asset Management Program, the client will pay an annualized fee (Account Fee) as set forth below. The Account Fee is negotiable and is payable quarterly in advance. The Account Fee referenced in this section includes all fees and charges for services of the Adviser. For the purposes of calculating Account Fees and providing quarterly performance reports, the account quarter will begin on the first day of the month in which the account is accepted by CWS unless the client chooses a different quarterly cycle. The annual fee for investment supervisory services will be charged as a percentage of assets under management. A minimum of $25,000 of assets under management is required for this service. Assets Under Management $25,000 - $249,999 $250,000 - $499,999 $500,000 - $1,000,000 Over $1,000,000 Fee 1.50% 1.25% 1.00% Negotiable The initial Account Fee is due at the beginning of the quarter following execution of the Management Agreement and will include the prorated fee for the initial quarter in addition to the standard quarterly fee for the upcoming quarter. Subsequent Account Fee payments are due and will be assessed at the beginning of each quarter based on the value of the account assets under management as of the close 4  of business on the last day of the preceding quarter as valued by an independent pricing service, where available, or otherwise in good faith as reflected on the client’s quarterly portfolio evaluation report. Additional deposits of funds and/or securities will be subject to the same billing procedures. This include deposits of no-load and load-waived mutual funds, equities, fixed income, annuities and any other securities approved for investment in the Asset Management Program. Advisory fees may be directly debited from a client account only if the client provides written authorization permitting CWS’s fees to be paid directly from the client's account held by an independent custodian and the custodian agrees to send to the client a statement, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to CWS. These fees and expenses are described in each fund prospectus. These fees will generally include a management fee, other fund expenses and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client can invest in a mutual fund directly with the mutual fund company, without the services of CWS, in which case, client will not receive the services of CWS, which are designed, among other things, to assist in determining which mutual fund(s) are most appropriate for the clients' condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by CWS to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. In addition to CWS's advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker/dealers, including but not limited to, any transaction charges imposed by a broker/dealer with which an independent investment manager effects transactions for the clients' accounts. Each investment advisory agreement provides that the agreement between client and Adviser shall be continuous until terminated by either party. Each agreement provides that the client may terminate the agreement within five (5) business days of its effective date without paying any fees or penalties. The agreement also provides that once the initial five (5) day period has passed, eitherparty to the agreement may terminate the agreement at any time by providing thirty days' written notice to the other party. If the appropriate disclosure statement is not delivered to the client at least 48 hours prior to the client entering into any written advisory contract with this investment adviser, then the client has the right to terminate the contract without penalty within five (5) business days after entering into the contract. Upon termination, it is the client's responsibility to monitor the securities in the Account, and the Adviser will have no further obligation to act on or provide advice with respect to those assets. If the agreement is terminated partway through a calendar quarter, fees collected in advance will be refunded to the client on a pro-rata basis, based on the number of days remaining in the calendar quarter following the effective date of termination. No fees will be accepted that are $1,200 or more and 6 months in advance. Clients should be aware that there always exists the potential for a conflict of interest in any such arrangement in which the person making the recommendation will receive remuneration for performing actions such as insurance sales. An adviser’s primary duty is fiduciary; any recommendation made must always be in the client’s own best interest. Under the American Funds program as a participant the client will pay Advisory fees an annualized fee (Account Fee) as set forth below. The Account Fee is negotiable and is payable quarterly in advance. The Account Fee referenced in this section includes all fees and charges for services of the Adviser. For the purposes of calculating Account Fees and providing quarterly performance reports, the account quarter will begin on the first day of the month in which the account is accepted by CWS unless the client chooses a different quarterly cycle. 5  Assets Under Management $0 - $99,999 $100,000 - $499,999 $500,000 and up Fee 75 Basis Points 50 Basis Points 25 Basis Points The annual fee for investment supervisory services will be charged as a percentage of assets under management. that may be directly debited from a client account only if the client provides written authorization permitting American Funds fees to be paid directly from the client's account held by an independent custodian and the custodian agrees to send to the client a statement, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to CWS. These fees and expenses are described in each fund prospectus. These fees will generally include a management fee, other fund expenses and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client can invest in a mutual fund directly with the mutual fund company, without the services of CWS, in which case, client will not receive the services of CWS, which are designed, among other things, to assist in determining which mutual fund(s) are most appropriate for the clients' condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by CWS to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. In addition to CWS's advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker/dealers, including but not limited to, any transaction charges imposed by a broker/dealer with which an independent investment manager effects transactions for the clients' accounts. Each investment advisory agreement provides that the agreement between client and Adviser shall be continuous until terminated by either party. Each agreement provides that the client may terminate the agreement within five (5) business days of its effective date without paying any fees or penalties. The agreement also provides that once the initial five (5) day period has passed, either party to the agreement may terminate the agreement at any time by providing thirty days' written notice to the other party. If the appropriate disclosure statement is not delivered to the client at least 48 hours prior to the client entering into any written advisory contract with this investment adviser, then the client has the right to terminate the contract without penalty within five (5) business days after entering into the contract. Upon termination, it is the client's responsibility to monitor the securities in the Account, and the Adviser will have no further obligation to act on or provide advice with respect to those assets. If the agreement is terminated partway through a calendar quarter, fees collected in advance will be refunded to the client on a pro-rata basis, based on the number of days remaining in the calendar quarter following the effective date of termination. No fees will be accepted that are $1,200 or more and 6 months in advance. Clients should be aware that there always exists the potential for a conflict of interest in any such arrangement in which the person making the recommendation will receive remuneration for performing actions such as insurance sales. An adviser’s primary duty is fiduciary; any recommendation made must always be in the client’s own best interest. Financial Planning Financial plans are available with fees ranging from $2000 to $5000, based on the complexity of the plan. These fees are negotiable based on the complexity of the Plan. Consulting Clients may also receive investment advice on a limited basis. This may include advice on only an isolated area(s) of concern, such as estate planning, retirement planning, or any other specific topic. 6  CWS also provides specific consultation and administrative services regarding investment and financial concerns of the client. Additionally, CWS provides advice on non-securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. The standard fee for these services is an hourly rate of $150. However, the fee rate is negotiable and may be higher or lower depending on the complexity of the services. 6. PERFORMANCE BASED-FEES and SIDE-BY-SIDE MANAGEMENT CWS does not charge Performance-Based fees or conduct Side-By-Side Management. 7. TYPES OF CLIENTS CWS provides this service to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, and corporations. CWS will manage advisory accounts on a discretionary and non- discretionary basis. CWS does not require a minimum account size. 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES and RISK of Loss Advisory representatives may use, without limitation, any of the following methods of analysis, sources of information and investment strategies: financial newspapers and magazines; inspections of corporate activities; corporate rating services such as Morningstar; and annual reports, prospectuses and press releases. Advisory representatives may also utilize different investment strategies, based upon the needs of the client, which include long-term purchases, as well as trading. Investment advice may be offered on any investments held by a client at the start of the advisory relationship. In addition, advice will be given (but not necessarily recommendations) on all types of equity securities, mutual funds, certificate of deposits, corporate debt securities, municipal securities and government securities. The main risk involved with CWS investment strategies is market fluctuation. All clients are advised that investing in securities involves risk of loss that clients should be prepared to bear. The advisory representative assists the client with determining whether the client is able to bear such risks. 9. DISCIPLINARY INFORMATION CWS does not have any past or current disciplinary actions. Representatives of CWS have not been subject to disciplinary actions in the past ten (10) years. 10. OTHER FINANCIAL INDUSTRY ACTIVITIES and AFFILIATIONS CWS is under common ownership with CW Securities, LLC, a FINRA registered broker/dealer offering clients customary brokerage services for separate and typical compensation. However, no advisory client is obligated to use CWS in this capacity. All clients are free to choose the broker/dealer of their choice. The President and CWS associates have appointments as insurance agents with various insurance companies. In their capacity as insurance agents, these individuals may implement recommended insurance transactions for advisory clients for separate and typical compensation. CWS or individuals associated with CWS may buy or sells securities identical to those recommended to clients for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. It is the expressed policy of CWS that no person employed by CWS may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, therefore preventing such employees from benefiting from transactions placed on behalf of advisory clients. 7  11. CODE OF ETHICS, PATICIPATION or INTEREST in CLIENT TRANSACTIONS and PERSONAL TRADING A. CWS has adopted a Code of Ethics pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, as amended, to prevent violations of federal securities laws. The Code of Ethics is predicated on the principle that CWS owes a fiduciary duty to its clients. Accordingly, CWS expects all employees to act with honesty, integrity and professionalism and to adhere to federal securities laws. All officers, directors, members and employees of CWS and any other person who provides advice on behalf of CWS and is subject to CWS’s control and supervision are required to adhere to the Code of Ethics. CWS’s Code of Ethics allows the purchase of IPOs or private placements only with prior permission from CWS’s Chief Compliance Officer. Clients may request to receive, at no cost, a copy of CWS’s’ Code of Ethics, which contains its policies on employee trading, gifts, and outside business activities. Gifts of nominal value are acceptable, and all employees must disclose any outside business activities generating revenue, which must be approved by CWS’s Chief Compliance Officer. B. Buys or Sells for CWS Securities that CWS Representatives Also Recommend To Clients From time to time, CWS may recommend to clients that they purchase or sell specific securities or investments in which CWS, or its related personnel have some financial interest. In addition, CWS or individuals associated with CWS may buy, sell, or hold in their personal accounts the same securities that CWS recommends to its clients and in accordance with its internal compliance procedures. Such trades will occur simultaneously with or after trades placed on behalf of clients. To minimize conflicts of interest, and to maintain the fiduciary responsibility CWS has for its clients established the following policy: An officer, director, or employee of CWS shall not buy or sell securities for a personal portfolio when the decision to purchase is substantially derived, in whole or in part, by reason of employment with CWS, unless the information is also available to the investing public on reasonable inquiry. No person associated with CWS shall prefer his or her own interest to that of any client. Personal trades in securities being purchased or sold for clients may be effected simultaneously with or after trades are effected for clients. CWS personnel may not anticipate trades to be placed for clients. C. Participation or Interest in Client Transactions CWS or individuals associated with CWS may buy, sell, or hold in their personal accounts the same securities that CWS recommends to its clients and in accordance with its internal compliance procedures. Such trades will occur simultaneously with or after trades placed on behalf of clients. To minimize conflicts of interest, and to maintain the fiduciary responsibility CWS has for its clients established the following policy: An officer, director, or employee of CWS shall not buy or sell securities for a personal portfolio when the decision to purchase is substantially derived, in whole or in part, by reason of employment with CWS, unless the information is also available to the investing public on reasonable inquiry. No person associated with CWS shall prefer his or her own interest to that of any client. Personal trades in securities being purchased or sold for clients may be affected simultaneously with or after trades are effected for clients. CWS personnel may not anticipate trades to be placed for clients. E. Fiduciary Status When CW Securities, LLC provides investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title 1 of the Employee Retirement Income Security Act and/or Internal Revenue Code, as applicable which are laws governing retirement accounts. The way in which CW Securities, LLC is compensated creates some conflicts with your interests, therefore CW Securities, LLC operates under a special rule that requires us to act in your best interest and not put our interests ahead of yours. 12. BROKERAGE PRACTICES Because CWS utilizes the platforms of Schwab, clients contractually agree to use these firms to execute transaction(s). Custody of account assets will also be maintained with these firms. CWS has evaluated 8  Schwab and believes that either will provide clients with a blend of execution/custodial services and professionalism that will assist CWS in obtaining best execution for transactions. American Funds custodies the 401k Plans and transactions are executed via application and reinvestment. While CWS has a reasonable belief Schwab and American Funds are able to obtain best execution and competitive prices, CWS will not be independently seeking best execution price capability through other broker/dealers. Clients understand and acknowledge that instructing CWS to execute all transactions on behalf of the account through Schwab and/or American Funds, a disparity may exist between the commissions borne by CWS's other clients that may be using a broker/dealer other than Schwab and/or American Funds. Clients opting to use a broker/dealer other than Schwab and/or American Funds may forego benefits that CWS may be able to obtain for its clients through, for example, negotiating volume discounts or block trades. 12.A.1.(a) Incentives When we use client brokerage commissions (or markups or markdowns) to obtain research or other products or services we receive a benefit because we do not have to produce or pay for the research, products or services. 12.A.1.(b) We may have an incentive to select or recommend a broker dealer based on our interest in receiving. the benefit of the research or other products or services rather than on our client’s interest in receiving the most favorable execution. When we use client brokerage commissions (or markup or markdowns) or pay for the research, products or services”. The President and CWS associates have appointments as insurance agents with various insurance companies. In their capacity as insurance agents, these individuals implement recommended insurance transactions for advisory clients for separate and typical compensation. 12.A.2. Brokerage for Client Referrals CWS does not have the incentive to select or recommend a broker/dealer based on its interest in receiving client referrals. 12.A.3. Directed Brokerage Certain clients may direct CWS to use particular brokers for executing transactions in their accounts. To the extent brokerage transactions are placed with particular brokers as directed by a client, CWS’s ability to achieve best execution may be eliminated. Clients who direct CWS to use particular brokers may pay higher commissions than those that do not. CWS reserves the right to decline acceptance of any client account that directs the use of a broker dealer other than Schwab or American Funds, if CWS believes that the broker dealer would adversely affect CWS’s fiduciary duty to the client and/or ability to effectively service the client portfolio. 12.A.4. Aggregation and Allocation of Trades It is the objective of CWS to provide a means of allocating trading and investment opportunities between advisory clients on a fair and equitable basis and in compliance with all applicable state and federal guidelines. With respect to clients’ accounts with substantially similar investment objectives and policies, CWS may often seek to purchase or sell a particular security in each account. CWS will aggregate orders only when such aggregation is consistent with CWS’s duty to seek best execution and is consistent with the investment objective of each client. No client account will be unfairly favored over any other account. Each client that participates in an aggregated order will participate based on the average execution price in that particular security. All transaction costs will be allocated pro rata based on each client’s participation in the transaction. All securities purchased or sold, whether the order is filled completely or partially, will then be allocated pro rata based on the assets of each account. 9  13. REVIEW OF ACCOUNTS Asset Management Program Reviews While the underlying securities within Asset Management Program accounts are continuously monitored, these accounts are reviewed no less frequently than annually. Accounts are reviewed in the context of each client's stated investment objectives and guidelines, ensuring that the structure of the portfolio is coordinated with these objectives. In addition, investment returns will be measured against the appropriate benchmarks in each asset class. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. Reports Clients will receive statements at least quarterly. Additionally, monthly statements will be generated as a result of investment activity by the client's separate custodian. Confirmation statements will be issued for all trading activity. Monthly and/or quarterly statements will include portfolio holdings, dates and amounts of transactions, and current and prior statement values. Financial Planning Reviews These client accounts will be reviewed as contracted for at the inception of the advisory relationship. Reports Financial Planning clients will receive a completed financial plan. Additional reports will not typically be provided unless otherwise contracted for at the inception of the advisory relationship. Consulting Services Reviews These client accounts will be reviewed as contracted for at the inception of the advisory relationship. Reports Due to the nature of this service, CWS will not typically provide reports unless contracted for at the inception of the advisory relationship. All client accounts are reviewed by the Chief Compliance Officer of CWS. 14. CLIENT REFERRALS AND OTHER COMPENSATION to its associates may, from time time, receive incentive awards for CWS and/or the recommendation/introduction of investment products. The receipt of this compensation may affect the judgment in recommending products to clients. While these individuals endeavor at all times to put the clients' interests first as part of CWS's fiduciary duty, clients should be aware that the receipt of these incentives may affect the judgment when making recommendations/introductions. Investment advisory fees deducted directly from client accounts; CWS participates in the institutional service programs offered by Schwab and American Funds. While there is no direct linkage between the investment advice given and the participation in these programs, economic benefits are received if CWS did not give investment advice to clients. These benefits may include any or all the following: • Receipt of duplicate confirmations and bundled duplicate statements; • Access to a trading desk serving program participants exclusively; • Access to block trading which provides the ability to aggregate transactions; • • Access, for a fee, to an electronic communications network for order entry and account information; • Compliance publications; and • Access to mutual funds which generally require significantly higher minimum initial investment requirements and are generally available only to institutional accounts. 10  Additional benefits received through participation in these programs may depend upon the amount of transactions directed to, or the amount of assets custodied by Schwab. CWS is required to maintain a minimum level of client assets with the Schwab program to avoid a quarterly service fee. 15. CUSTODY CWS does not have custody of any client funds or securities. Clients should carefully review statements they receive from custodians. 16. INVESTMENT DISCRETION CWS requests that it be provided with written authority (Limited Power of Attorney) to determine the amounts of securities that are bought or sold. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change or amend these limitations as required. All such amendments shall be submitted in writing. CWS generally has discretionary authority to make the following determinations without obtaining the consent of the client before the transactions are effected: (1) which securities are bought and sold for the account and (2) the total amount of securities to be bought and sold. CWS’s’ authority in making investment-related decisions may be limited by account guidelines, investment objectives and trading restrictions, as agreed between CWS and the client. 17.A. VOTING CLIENT SECURITIES CWS does not vote proxies on behalf of its clients. Therefore, although CWS may provide investment advisory services relative to client investment assets, CWS’s clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceeding or other type events pertaining to the client’s investment assets. CWS and/or the client shall correspondingly instruct each custodian of the assets to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. 17.B. Clients will receive their proxies or other solicitations directly from their custodian or a transfer agent clients may contact CWS with questions about a particular solicitation. 18. FINANCIAL INFORMATION Prepayments CWS does not require or solicit prepayments of more than $1,200 in fees per client, six (6) months or more in advance. 18.B. Financial Condition There are no financial conditions that are likely to impair CWS’s ability to meet its commitments to clients. 18.C. Bankruptcy CWS has not ever been subject to bankruptcy. CLIENT COMPLAINTS Clients may contact Michael Cox, Chief Compliance Officer of CW Securities, LLC, at (865) 690-9886 or mcox@cwmanagement.com to submit a complaint. Written complaints should be sent to CW Securities, LLC, 8870 Cedar Springs Lane, Suite 208, Knoxville, TN 37923 CLIENT ACKNOWLEDGEMENT The undersigned client acknowledges that he or she has received, read and understands the contents of this Disclosure Brochure. 11  CLIENT(S) ________________________________ Date _________________________________ ________________________________ Date _________________________________ CW Securities, LLC Date _________________________________ By _______________________________________ Signature and Title 12